European Biochar Industry Consortium
EBI
Integrating biochar into the European policy and regulatory landscape guiding informed decision-making.
ID: 124632237702-53
Lobbying Activity
22 Sept 2025
We appreciate the efforts and thank the commission for this thorough work over the last years. Please find our feedback attacked
Read full response25 Jun 2025
Incorporating permanent CDR into the EU ETS is critical to achieving net-zero by 2025. To succeed, this integration must unlock large-scale private financing, establish a predictable market for removals, and maintain technology neutrality to support a diverse portfolio of CRCF-certified, permanent CDR. BCR is delivering climate impact already. In 2023, the European biochar industry removed 130,000 tonnes COe, accounting for over 90% of all durable carbon removals (cdr.fyi). BCR is mature, scalable, and technologically proven (TRL >8). It requires no costly infrastructure like pipelines or geological storage, enabling rapid deployment. With the right policy and market signals, BCR could deliver 2.4 Mt of COe removals annually by 2030. The CRCF ensures high-quality, certified removals through robust methodologies. It supports transparency, rigorous monitoring, and the durability of removals essential elements of a trustworthy CDR market. The EU ETS should recognize CRCF-certified removals, including BCR, without adding new technical or legal hurdles that would undermine coherence, create unfair advantages, or slow progress. Including CRCF-certified BCR in the ETS offers strong economic benefits. BCR delivers permanent CDR at relatively low cost due to its co-benefits (e.g. renewable energy, valuable biochar products), with a relatively small price gap to EUA levels. This reduces the need for public subsidies. Allowing all permanent CDR types to compete in the same market will naturally establish a technology-neutral price, supporting efficiency and innovation. Liability considerations must reflect the nature of BCR. Once biochar is embedded in materials like asphalt or cement and combustion is prevented, the risk of reversal is negligibleunlike geological storage of CO. If additional safeguards are needed, they can be managed via mechanisms like bank insurance. Strict CCS liability rules would be incompatible not only with BCR, but also with other emerging pathways like enhanced weathering and ocean-based removal, where carbon fate cannot be precisely monitored. BCR is uniquely ready to deliver scalable, verifiable, and permanent CDR today. Unlike other technologies, which still remain in demonstration phases and require extensive infrastructure, BCR can immediately ramp up production, given political support. Including BCR in the EU ETS would provide a reliable, low-cost compliance option, while safeguarding against delays or underperformance from unproven technologies.
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
Biochar as the Key to a Climate-Neutral, Competitive, and Resilient European Economy Biochar Europe appreciates the opportunity to contribute to the European Commissions consultation on its forthcoming Bioeconomy Strategy, as outlined in the initiative Towards a Circular, Regenerative and Competitive Bioeconomy (Q4-2025) Circular Bioeconomy. The strategys focus on circularity, sustainability, industrial competitiveness, and rural resilience aligns closely with the result of our recent White Paper: The production and use of biochar, a carbon-rich solid derived from biomass pyrolysis, holds transformative potential to decarbonize Europes industrial base, regenerate soils, and foster new economic opportunities across rural regions. Our contribution builds on the EUs ambitions to: Reduce dependency on fossil feedstocks through sustainable bio-based value chains; Improve resource efficiency and biomass valorisation across sectors; Address climate and biodiversity goals via innovation in primary production; Enable SMEs and farmers to become central actors in the bioeconomy. The white paper specifically highlights the role of biochar in metallurgical industries as both a direct replacement for fossil carbon and an enabler of circular, climate-positive processes. We present case studies and scientific data illustrating biochars viability for substituting fossil reductants in industries such as silicon, steel, and non-ferrous metals. Furthermore, we analyse the current policy, regulatory, and market barriers impeding large-scale deployment and offer recommendations for an EU-wide enabling framework. Key Recommendations Recognize biochar as a strategic bio-based material within EU industrial and bioeconomy policies. Develop harmonised standards and certification systems for biochar across sectors. Support demonstration projects and scale-up funding to bridge the innovation-commercialization gap. Incentivize primary producers (foresters, farmers) for biomass supply and carbon removal services. Integrate biochar use into rural development programs and industrial decarbonisation policies. Relevance to the EU Bioeconomy Strategy This paper directly addresses several of the Commissions stated goals, including unlocking high-value applications for sustainable biomass, building a Circular Bioeconomy, reinforcing EU industrial competitiveness, and empowering rural actors in the green transition. Biochar production embodies the cascading use principle, delivering multiple environmental and economic co-benefits across the bioeconomys value chains. It offers a practical, shovel-ready tool to accelerate the deployment of clean technologies while enhancing biodiversity, soil fertility, and carbon sequestration. We welcome the opportunity to contribute to the EUs vision for a sustainable, circular, and sovereign bioeconomy and are ready to engage further in this strategic dialogue.
Read full responseResponse to Delegated act on primarily used components under the Net-Zero Industry Act
20 Feb 2025
Biochar, derived through pyrolysis of biomass, can be processed into components in industrial applications that directly contribute to the EUs defossilization goals. When engineered to precise standards, it can serve as a sustainable and renewable feedstock for a variety of industrial applications. While biochars can contribute to achieving net-zero targets in a larger range of industrial sectors, we want to highlight two distinct applications, where we see not only a large potential, but no alternative to the use of high-grade engineered biocarbons: In metallurgical processes and the construction sector, particularly concrete. It is clear that by integrating biochar into these components, the EU can reduce reliance on fossil-based inputs and achieve meaningful carbon reductions throughout their supply chains. Metallurgy Biochar is the first and last step to defossilizing metallurgy. Green carbon is essential for the green transition of metallurgical industries, which are traditionally reliant on carbon-intensive fossil resources. The integration of biochar into metallurgical processes offers a way to replace non-renewable carbon sources with sustainable, carbon-neutral alternatives. The production of biochar from biomass helps upgrade residue streams, transforming them into valuable carbon resources, while also minimizing environmental impact. In certain metallurgical processes, like the production of silicon for photovoltaics, there is no substitute for carbon as a reductant. The only alternative to fossil carbon sources is high-purity biochar with an elevated carbon content. The replacement of one ton of fossil carbon can, in this case, helps reducing emissions by 5 tons of CO2e. View Biochar Europes Position Paper Metallurgy for more information. Construction Given its versatile applications and performance characteristics, concrete is likely to remain the construction material of choice globally. Yet construction, particularly the production and use of cementitious products, is contributing considerably to climate change. Cement production alone is responsible for 8% of the global greenhouse gas emissions. Biochar-based products present a compelling solution for concrete producers seeking to defossilize their value chains in the short term and actively remove carbon from the atmosphere durably for a transformed industry capable of addressing their future residual emissions. Biochar-based products not only act as a partial replacement for cement and other carbon-intensive aggregates, but offer multifaceted benefits when incorporated into concrete mixes, storing the carbon removed from the atmosphere durably. The addition of biochar can enhance concrete's functional and mechanical properties, such as strength, long-term durability and thermal insulation. View Biochar Europes Position Paper on Biochar in Concrete Energy production In addition, the exothermic process of biochar production produces energy in the form of heat (steam) and power, contributing to EU clean energy targets. Europes technology leadership The EU currently enjoys a global market leadership by hosting a strong biochar manufacturing industry and technology development. However, it needs support to scale effectively, stay ahead of international competition, and bring European biochar materials and production technology to the European and global market. The EUs strong research and innovation ecosystem and established biochar manufacturing and processing facilities position it to remain a global leader in biochar-based technologies. By leveraging the regulatory, administrative and financial support offered by the Net-Zero Industry Act, the EU can strengthen its supply chains and manufacture supreme biochar technology for a global market global scale. We therefore call for the inclusion of a biochar category and sub-categories into the annex amending Regulation (EU) 2024/1735.
Read full responseMeeting with Stefan Köhler (Member of the European Parliament)
20 Feb 2025 · Politischer Austausch
Meeting with Elsi Katainen (Member of the European Parliament)
20 Feb 2025 · The status of the biochar sector
Meeting with Valérie Hayer (Member of the European Parliament)
16 Oct 2024 · Biochar
Meeting with Norbert Lins (Member of the European Parliament)
16 Oct 2024 · Carbon Removal
Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Acumen Public Affairs
4 May 2023 · EU certification framework for carbon removals
Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur)
3 May 2023 · Union certification framework for carbon removals
Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur for opinion)
3 May 2023 · Carbon Removal Certification
Response to Carbon Removal Certification
23 Mar 2023
In addition to emission avoidance and reduction, carbon removal remains the last chance to reach net zero within the timeframe envisaged by the EU. It is mandatory to compensate for hard-to-abate emissions and reduce the greenhouse gas concentration in the atmosphere to a level that preserves human habitats. The EU is leading the way by laying the groundwork for a carbon removal framework. If well elaborated, this framework will be the base for Europe to strengthen its position as a leader for climate protection technology, creating jobs and an attractive environment for young talents. The European Biochar Industry Consortium (EBI) strongly supports the elaboration of a union certification framework for carbon removals. We are honored to participate, as a member of the European Commission´s Carbon Removal Expert Group, in defining appropriate methodologies for verifiable, high-quality carbon removals. Biochar Carbon Removal (BCR) is an already established concept for result-based, high-quality carbon removal certificates, fostering the scaling-up of technological carbon removals on a EU level. Due to the incentives provided by carbon removal certificates, BCR will sequester 150.000 t CO2e in 2023 within the EU . In order to start scaling durable carbon removals to climate relevance in a timely manner, we urge the commission to focus on the following points: 1. Defining permanence by timescale rather than by location. 2. Setting a more ambitious industrial removal target of at least 10 Mt CO2e by 2030. 3. Providing a roadmap to scale carbon removals over a given timeframe. 4. Preventing the creation of barriers for existing removal technologies and concepts, while supporting additional sustainability aspects 5. Developing liability frameworks and MRVs for existing and future carbon removal technologies. Please find in the document attached a more detailed descriptions and sources on the points above. We extend our gratitude to the European Commission for their climate leadership and remain at your disposal in case of any questions and queries.
Read full responseMeeting with César Luena (Member of the European Parliament)
6 Feb 2023 · MEP Luena's Team on Carbon removals
Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)
6 Feb 2023 · Union certification framework for carbon removals
Meeting with Ville Niinistö (Member of the European Parliament)
24 Jan 2023 · Carbon removals (staff level)
24 Oct 2022
The European Biochar Industry (EBI) Consortium welcomes the Commission’s initiative to move towards the achievement of Green Deal in terms of nutrient circularity and thus support the EC aim to determinate end-points for certain derived products in the manufacturing chain. Therefore, allowing them to comply with Article 42(5) of the Fertilising Product Regulation (EC) 2019/1009 and be no longer subject to the requirements of Regulation (EC) No 1069/2009.
The EBI, a business and trade association representing over 70 members from more than 14 countries, support the determination of an end point in the manufacturing chain for animal manure and in general animal by-products, which result from animal husbandry and from processing of animals for human consumption, but which are inappropriate for food production, (category 2 and 3 of Reg. (EC) No 1069/1009), e.g. bone meal or manure.
Using animal manure as feedstock for pyrolysis could play a crucial role for nutrient recovering and a sustainable nutrient management. In 2021, a JRC‘s review of 407 papers, exploring manure and soil biodiversity, assessed how the physicochemical properties of manure can justify its wide use as soil improver and organic fertiliser. Among its benefits, it provides mineral nutrients, such as inorganic nitrogen (in the form of NH4+), carbon, phosphorous and sulphur. Moreover, a fertilising system including animal manure offers a win-win opportunity for enhancing agricultural productivity, reducing farmers‘ costs and enabling positive environmental effects.
However, manure’s positive impacts strongly depend on livestock typology, animal feed and manure management: an excessive amount of manure, applied during long period, will cause phosphorous and potassium accumulation, and nitrogen leakage. Further, pathogens may be contained, next to antibiotics, which are widespread in the livestock feed sector and are able to cause microbial-resistant genes. Microplastics represent another pollutant of concern, together with the presence of heavy metals. As concerns for using animal by-products as fertilizer are rising, adequate treatment like pyrolysis or gasification seems suitable to face this problem. Anyway, considering animal by-products as feedstock for CMC 14 today will already pave the way for already existing and upcoming challenges for a sustainable nutrient management and soil protection.
Please find attached the extensive version of EBI's comment.
Read full response9 Aug 2022
The European Biochar Industry (EBI) Consortium welcomes the Commission’s initiative for new reporting requirements on national energy climate plans. The EBI is a trade and business association representing over 60 members across the entire value chain of biochar located across more than 14 countries. Transparent, accurate and practical report frameworks are key to achieving the European Union’s climate targets. Reaching these targets in the respective timeframe are for many member states, due to their core economic sectors and structural backgrounds, great challenges. Further according to the IPCC, permanent carbon dioxide removal must be implemented in large scale to keep global warming within the targets set by the Paris Agreement. Therefore, the European Biochar Industry Consortium calls for an integration of technological carbon dioxide removal into the EU analysis of national policy measures.
Several documents and public consultations, e.g. EU’s Clean Planet for All Communication, Sustainable Carbon Cycle Communication, Carbon Removal Certification Mechanism, published by the EU already consider carbon dioxide removal technologies Nevertheless, carbon dioxide removal (CDR) just found its way into the business world, disregarded by most states. Irrespective of the reason, many countries are not on track to meet the set climate goals Therefore, existing scalable solutions for carbon dioxide removals remain the only possibility to still limit global warming within the Paris goals.
More than half of the European member states reduced their greenhouse gas emissions from 1990 to 2020 less than 30 % (European Environment Agency (2022) “Annual European Union greenhouse gas inventory 1990-2020 and inventory report 2022). Integrating carbon dioxide removals by negative emissions technologies into the national policy measures enables
• closing the carbon emissions gap,
• opening up the possibility for a fair distribution to balance carbon emission, while
• leaving member states the freedom to choose solutions according to national circumstances.
Please find the complete comment attached as PDF.
Read full responseResponse to Pyrolysis and gasification materials in EU fertilising products
12 Feb 2021
The European Biochar Industry Consortium very much welcomes and appreciates the Draft Delegated Act, particularly the wide base of possible input materials that are considered as feedstock. This supports the establishment of a circular economy as proposed under the EU Green Deal as well as national agendas of member states, also because it permits the valorization of previously hardly used residual material streams. Biomass pyrolysis as a key Negative Emission Technology will be essential for the achievement of the EU target to become climate neutral by 2050.
As much as we agree to the formulation of the Draft Delegated Act, we’d also like to add some thoughts for future adjustments/improvements of the regulation.
Some points that caught our attention were:
1. The minimum temperature and residence time for pyrolysis and gasification.
180°C and 2 seconds of residence time will not result in a product that could be defined as biochar. We therefore suggest a temperature above 350°C (according to the EBC guidelines) or better 400°C for pyrolysis. We also suggest to include an O/C ratio of < 0.4 (according to EBC), in order to assure long-term persistence of biochar in agricultural soils.
2. The PAH 16 limit of 6 mg/kg was set very cautiously, which is positive as there are harmful substances in the PAH class. Setting such a strict limit eliminates any possible threat to ecosystems. Still, no difference is made between toxic molecules like Benzo[a]pyrene and considerably less harmful ones like Naphthalene. We would therefore suggest to classify PAHs in future reviews.
3. In order to guarantee absolute safety for the environment and human health, a limit for Benzene should be defined in line with the REACH regulations. Annex XVII Nr. 5 of the REACH Regulation limits Benzene levels to a content of < 0,1 %. These levels can easily be undercut with state of art biochar production equipment.
4. Sustainable sourcing: it is well-recognized that any use of biomass should occur within sustainability boundaries. This implies management and harvesting principles providing safeguards against overharvesting and maintaining ecological sustainability. A paragraph on sustainable sourcing should be included in the next review.
5. Sewage sludge derived pyrolysates have not been considered in the positive list even though these products would allow the recuperation and direct use of phosphorous and other nutrients. To completely exclude even the possibility of including biosolids as pyrolysis feedstock would seal a huge potential of European environmental technology development and disadvantage Europe against the rest of the world in regard to nutrient and carbon recycling of sewage sludge. Several member states already permit the use of sewage sludge pyrolysates in agriculture. Due to the high mineral content of sewage sludge, the minimum carbon content should be adapted for this particular carbonisate.
Recent scientific papers demonstrate that at sufficiently severe pyrolysis temperatures (> 500°C) and residence times (> 3 min), all reference organic contaminants and organic micropollutants were completely or nearly completely degraded or driven off the solid material.
We would therefore like to draw your attention to the following key publications that show convincingly the efficiency of pyrolytic degradation of model hormones, antibiotics and other pharmaceuticals. We think that these peer reviewed scientific publications are a convincing base to review the decision and to open the possibility to include biosolids as eligible feedstock for pyrolysis. Please see attachment.
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